Security Over Regents Examinations

Thomas P. DiNapoli OFFICE OF THE COMPTROLLER NEW YORK STATE COMPTROLLER

DIVISION OF STATE GOVERNMENT ACCOUNTABILITY

Audit Objective...... 2 STATE EDUCATION Audit Results - Summary...... 2 DEPARTMENT Background...... 3

Audit Findings and Recommendations ...... 4 SECURITY OVER REGENTS

Storage of Examination Materials ....4 EXAMINATIONS Recommendations...... 10 Shipments of Examination Materials ...... 10 Recommendations...... 11 Monitoring by SED ...... 12 Recommendations...... 12 Report 2006-S-104

Audit Scope and Methodology.....12

Authority...... 14

Reporting Requirements...... 14

Contributors to the Report ...... 14

Exhibit A ...... 15

Appendix A - Audit Response...... 19

AUDIT OBJECTIVE selected a representative sample of 235 schools administering exams during the Our objective was to determine whether January 2007 Regents examination period adequate security is maintained over Regents (January 23 through January 26, 2007). We examinations from the time the examination found that 41 of the 235 schools (17 percent) materials are received by the schools until the were not fully complying with the day the examinations are given. requirements for the storage and unsealing of the examination materials. For example, 16 AUDIT RESULTS - SUMMARY schools were storing their examination materials in unapproved locations, some of Regents examinations are statewide tests for which were clearly not secure (such as a high school students in particular subject principal’s office), and 11 schools had opened areas. The examinations are developed by the sealed packages of examination materials State Education Department (SED) and before the allowed time (in most instances, administered by participating high schools. one or more days before the examinations To preserve the integrity of the examination were scheduled). As a result of these process, each individual examination is given inappropriate actions, the risk of security on the same day, at the same time, by each breaches was increased at these 41 schools. participating high school. In addition, the schools are required by SED to follow certain At many of the non-compliant schools, school security-related procedures in their handling officials were not aware of the security of the examination materials (e.g., test requirements. We recommend SED develop booklets and answer keys). and provide security awareness training for the schools. In addition, SED sometimes These materials are printed by SED and visits selected schools during Regents shipped to the schools shortly before the examination periods to determine whether examinations are scheduled to be given. The their examination materials are adequately materials are shipped in sealed, labeled secured. Although, such visits help to packages inside of locked Regents boxes. strengthen security practices at the schools, The schools are supposed to inventory the we found the visits are not made regularly and packages upon receipt, place the packages relatively few schools are visited. For back into the boxes, and store the locked example, only 57 of the 235 schools in our boxes in an approved safe or vault until the sample had been visited since 1992. We day of the examination. Under no recommend SED increase the number of these circumstances are any of the sealed packages visits. to be opened before the day of the examination. The sealed packages are to be This report, dated June 5, 2007, is available opened only on the day of the examination on our website at: http://www.osc.state.ny.us. and only shortly before the examination is to Add or update your mailing list address by be administered. contacting us at: (518) 474-3271 or Office of the State Comptroller To determine whether the schools were Division of State Government Accountability complying with these requirements, we 110 State Street, 11th Floor Albany, NY 12236

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BACKGROUND Outside New York City, most schools receive a single shipment of examination materials in Regents examinations are statewide tests that each examination period. The shipment are given each year in particular subject areas, usually arrives about three days before the such as English, history, mathematics, first test is scheduled. In New York City, science, and various foreign languages. They schools receive daily shipments of are intended to assist colleges in making examination materials. Each day, the schools admission decisions and to provide a measure receive the tests for the following day and the of accountability over school effectiveness answer keys for that day’s tests. Daily and adherence to the State’s prescribed shipments are also sent to some schools curricula. In addition, certain Regents outside New York City. examinations must be taken before high school students are allowed to graduate. All examination materials are shipped in Regents examinations have been given in sealed packages inside of locked Regents New York State since 1878. The boxes. At the schools, the packages are to be examinations are developed by the State stored inside these boxes, and the boxes are to Education Department (SED) and be stored in an approved safe or vault to administered by participating high schools. preclude access by students or other unauthorized persons. School officials are The questions used in Regents examinations required to inventory the packages, which are are developed by SED’s Office for Standards, labeled for content and quantity, as soon after Assessment and Reporting. The individual receipt as practical, but the packages are not examinations, the corresponding answer keys, to be opened until the day of the test, and not and the teacher dictation copies of the before a certain time on that day. SED has examinations are printed by SED’s Print designated 75 strategically located regional Shop. The examination materials are then distribution centers to ensure that extra distributed by contractors to the participating examination materials are available to schools high schools. Generally, each individual in case of emergency. The regional centers examination is to be given on the same day, at are staffed by local school officials. the same time, by each participating high school. If a school does not have an approved safe or vault, it must make arrangements to store its Most of the examinations are given in June, examination materials in a nearby school’s when about 3 million tests are shipped to approved safe or vault. Schools agreeing to more than 2,000 schools. However, some of store examination materials for other schools the examinations are also given in August and are considered “host schools.” Host schools January (more than one million tests were must not open the locked Regents boxes of shipped to schools in January 2007). Local “guest schools.” Rather, officials from the school administrators are responsible for guest schools should open the boxes and maintaining security over the examination inventory the materials. The materials must materials once they have been delivered. The then remain in storage at the host schools local administrators are also responsible for until the day of the examination. grading the tests and posting the results to the students’ permanent records. After an examination is given the examination materials no longer need to be kept secure, unless the examination is classified by SED as

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“restricted.” Since questions in restricted we selected schools from all regions in the examinations may be re-used in future State; schools that were administering both a examinations, the individual tests, the teacher relatively large and a relatively small number dictation copies, and the answer keys must be of examinations; a number of host and guest collected and returned to SED. Our audit did schools; a mixture of city, rural and suburban not address the additional security schools; and a mixture of public, private and requirements for restricted examinations. charter schools. Our sample contained a total of 179 public schools, 51 private schools, and The most recent known breach of Regents 5 charter schools. The schools are listed in examination security occurred in June 2005 at Exhibit A. Jericho High School, which is located on Long Island. In this breach, an assistant We found that 36 of the 235 schools (15 principal opened the answer keys to the percent) did not fully comply with SED’s Global History exam before the day of the storage requirements for Regents examination exam and shared the answers with his son, materials, as follows: who was scheduled to take the exam at another school. • 13 schools were storing examination materials in unapproved locations, AUDIT FINDINGS AND some of which were clearly not secure. RECOMMENDATIONS In addition, while all 13 schools were keeping the materials inside Regents Storage of Examination Materials boxes, as required, one of the schools was not keeping the boxes locked. According to SED requirements, once the examination materials have been delivered to • 14 schools were not keeping their a school, they must be stored in an approved examination materials inside Regents safe or vault until the day of the examination. boxes. While all 14 schools were Moreover, the materials must be kept inside storing the materials inside an their Regents boxes while they are in the safe approved safe or vault, they were not or vault, and the boxes themselves must be providing the full measure of security kept locked. These stringent security required by SED. requirements are intended to ensure that the integrity of the examinations is preserved. • 6 schools were storing their examination materials in an approved To determine whether local school safe or vault, and keeping the materials administrators were complying with these inside Regents boxes, but were not storage requirements, we selected a sample of keeping the Regents boxes locked. As 235 schools and visited their Regents a result, they were not providing the examination storage locations either during, full measure of security required by or just prior to, the January 2007 Regents SED. examination period (January 23 through January 26, 2007). Our sample was selected • 3 guest schools were removing their from the 1,554 public, private and charter examination materials from their schools listed in SED records as participating approved host schools before the day in Regents examinations in January 2007. To of the examination and storing the make our judgmental sample representative,

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materials in an unapproved location for incorporated in Underwriters as long as four days. Laboratories (UL) classification TRTL-30, and must have all of the As a result of this non-compliance with following: a steel door at least one and SED’s storage requirements, the risk of one-half inches thick; steel walls at security breaches was increased at these 36 least one inch thick; a minimum weight schools. As is described later in the section of of 750 pounds; a built-in combination this report entitled Opening of Sealed lock; and enough space inside to Packages, 6 of these 36 schools also opened contain the Regents box(s) for the sealed packages of examination materials school’s typical examination period. before the allowed time and, as a result, further compromised the security over their • Walk-in vaults must have all the Regents examinations. Details about our following: a poured concrete floor; findings at the 36 schools follow. walls of reinforced concrete or reinforced cement block, sealed to a Storage Locations Not Approved by SED poured concrete floor below and a structural floor or roof deck above; a SED’s School Administrator’s Manual, 2001 metal door in a metal frame with inside Edition, contains specific guidelines for the or welded-pin hinges; no windows or storage of examination materials at the access panels; and a built-in dead schools. The Manual states that “the principal latching combination or key lock that of each school requesting examinations is allows exiting at all times. responsible for making the necessary arrangements for safeguarding the materials The principals for all of the schools in our shipped to the school.” Specifically, the sample storing examination materials principal must certify that the locked Regents certified that locked Regents box(s) box(s) containing the examination materials containing the examination materials were are stored in a safe or walk-in vault that has stored in a safe or walk-in vault that had been approved by SED. been approved by SED. However, when we visited the schools, we found that 13 To be approved by SED, a safe or walk-in schools were storing their examination vault must meet the following specifications: materials in locations that had not been approved by SED. SED had approved • Safes must meet or exceed the burglary storage locations at all 13 of the schools, resistance performance standards but the schools were storing their examination materials in other locations.

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The 13 non-compliant schools are listed in the following table:

School Type County Archbishop Stepinac High School Private Westchester Bishop Timon High School Private Erie Brooklyn International High School Public Brooklyn Laurens Central School Public Otsego Notre Dame School (Manhattan) Private Manhattan Renaissance Charter School Charter Queens Saranac Lake High School Public Franklin Sacred Heart High School Private Westchester Solomon Schechter School Private Nassau St. Michael Academy Private Manhattan South Bronx Preparatory High School Public Bronx Urban Assembly School of Law & Justice Public Brooklyn Whitesville Central School Public Allegany

At some of the schools, the storage locations windows that were plainly visible from the had obvious security weaknesses and were outside of the building. clearly not secure. For example, at Solomon Schechter High School in Glen Cove, the We immediately notified SED about the lack boxes containing the examination materials of adequate security at these four schools, and were being stored in plain sight in the SED immediately contacted the schools and assistant principal’s office both during school instructed school officials to move the hours and at night. Officials at Solomon examination materials to secure locations at Schechter High School told us they were not other schools. All four schools have lost their aware they were supposed to store the storage privileges for at least one year, during examination materials in a safe or vault, and which time they must arrange for their had been keeping them in the assistant examination materials to be stored at host principal’s office for years. schools.

Similarly, at Saranac Lake High School, the At the other nine schools, the examination boxes containing the examination materials materials were being stored in safes or vaults, were being stored in plain sight in the but the safes or vaults (which had not been principal’s office, because there was not approve by SED) failed to meet SED’s enough room in the safe to store the materials. specifications (e.g., some of the vaults had At Bishop Timon High School in Buffalo and wooden doors or walls made of sheetrock). Archbishop Stepinac High School in We informed SED officials about the security Westchester County, the boxes containing the weaknesses at these nine schools. SED examination materials were being stored in officials told us they plan to review this vaults that were not secure because, contrary information and determine whether the to SED’s specifications, both vaults contained schools should be allowed to retain their storage privileges. We recommend SED

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make these determinations before the June School Type County 2007 Regents examination period. Andover High School Public Allegany Brookfield HS Public Madison We note that all 13 schools were keeping their Carmel High School Public Putnam examination materials inside Regents boxes, East Hampton School Public Suffolk as required, but one of the schools (Saranac Genesee Valley at Angelica Public Allegany Lake High School) was not keeping the boxes Herbert H. Lehman HS Public Bronx locked. In addition, as is described in more Mayfield High School Public Fulton detail later in this report, we found that two of New Paltz High School Public Ulster the schools (Archbishop Stepinac High Patchogue-Medford Public Suffolk School and Saranac Lake High School) St. Lawrence opened sealed packages of examination Potsdam High School Public materials before the allowed time and, as a Scio Central School Public Allegany result, further compromised the security over Southside High School Public Chemung their Regents examinations. We recommend Wells Central School Public Hamilton SED develop and provide security awareness White Plains HS Public Westchester training for schools administering Regents examinations to ensure the schools are Officials from one of these schools (East familiar with their security requirements. Hampton High School) told us their storage location was not large enough to hold the Examination Materials Not Stored in Regents boxes, and that was why they took Regents Boxes the examination materials out of the boxes. However, the School Administrator’s Manual The School Administrator’s Manual states states that the location must be large enough that “…all secure examination materials for “to contain the Regents box(s) for the each examination must be stored in the locked school’s typical examination period.” In Regents box in a safe or vault until the addition, as is described in more detail later in morning of the day of the test.” However, 14 this report, two of these schools (Herbert H. of the schools in our sample were not keeping Lehman High School and White Plains High their examination materials inside Regents School) opened their sealed packages of boxes; rather, they took the sealed packages examination materials before the allowed time out of the Regents boxes and stored the and thus further compromised the security packages in an approved safe or vault. As a over their Regents examinations. result, they did not provide the full measure of security required by SED. The 14 non- Regents Boxes Not Locked compliant schools are listed in the following table: The School Administrator’s Manual states that the examination materials must be stored in locked Regents boxes. However, seven of the schools in our sample were not complying with this requirement. Six of the schools were storing their examination materials in an approved safe or vault, and were keeping the materials inside Regents boxes. However, they were not keeping the Regents boxes locked. As was previously noted, the seventh

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school (Saranac Lake High School) was School Type County storing its examination materials in an Archbishop Walsh HS Private Cattaraugus unapproved location (the principal’s office). Finger Lakes Christian Private Seneca This school was storing its materials in School Regents boxes, but the boxes were not locked. Vanderheyden Hall* Private Rensselaer The seven non-compliant schools are listed in the following table. * Vanderheyden Hall was not included in our sample. However, its host school, Averill Park Central School Type County School, was included in our sample. Since SED Bayside High School Public Queens security requirements were violated at the host school, we are including the violation in our sample Curtis High School Public Staten Island results. Franklin Central Public Delaware School Two of these schools (Archbishop Walsh Mamaroneck HS Public Westchester High School and Vanderheyden Hall) Newark Senior High Public Wayne removed all their examination materials for School the week from the host school on Monday, NYC Lab H. S. for Public Manhattan January 22, 2007. The third school (Finger Collaborative Studies Lakes Christian School) removed all its Saranac Lake HS Public Franklin examination materials from the host school on Tuesday, January 23, 2007. Once the As is described in more detail later in this examination materials were removed from the report, we also found that three of these host schools, they were stored in unapproved schools (Curtis High School, Mamaroneck locations for as long as four days. As a result, High School, and Saranac Lake High School) during these intervals, the security over these opened sealed packages of examination Regents examinations was compromised. materials before the allowed time, and thus further compromised the security over their Opening of Sealed Packages Regents examinations. The School Administrator’s Manual states Examination Materials Removed Too Soon that the sealed packages of examination From Host Schools materials should be inventoried by school officials as soon after receipt as practical, but The School Administrator’s Manual states under no conditions are the packages to be that guest schools may not remove their opened before the day of the examination. In examination materials from host schools addition, if an examination is scheduled for before the day of the examination. Our the afternoon, the sealed packages for that sample included a total of 19 guest schools, examination should not be opened until and we found that two of these schools did shortly before the examination is scheduled to not comply with this requirement. In be given. addition, when we were at one of the host schools in our sample, we happened to We found that 11 of the schools in our sample observe an official from its guest school did not comply with these requirements, and removing examination materials before the had opened some or all of their materials day of the examination. The three non- before the allowed time (in most instances, compliant schools are listed in the following table.

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the schools opened the materials one or more addition, as was previously noted, six of these days before the examinations were schools also failed to comply with one or scheduled). Three schools opened all their more of the SED’s storage requirements for materials early, seven schools opened their the examination materials. tests early and one school opened its answer keys early. By opening the sealed tests and/or The 11 non-compliant schools are listed in the answer keys before the allowed time, the following table (the six not complying with officials at these schools compromised the other storage-related requirements are integrity of their Regents examinations. In bolded):

School Type County Materials Opened Archbishop Stepinac High School Private Westchester Tests Auburn High School Public Cayuga Tests/Answers Curtis High School Public Staten Island Tests Hempstead High School Public Nassau Tests/Answers Herbert H. Lehman High School Public Bronx Tests John S. Burke Catholic High School Private Orange Tests Lockport High School Public Niagara Tests/Answers Mamaroneck High School Public Westchester Tests Saranac Lake High School Public Franklin Tests Thomas R. Proctor High School Public Oneida Answers White Plains High School Public Westchester Tests

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At some of the schools, the officials said Recommendations they were not aware they were not supposed to open the materials before the day of the 1. Develop and provide security awareness examination. At other schools, the officials training for schools administering said they were aware of the prescribed Regents examinations to ensure that the procedures, but were concerned that they schools are familiar with their security might not have received the proper numbers requirements. of tests and/or answer keys. They therefore opened the packages to confirm that they 2. Determine whether the schools using had everything they needed. We note that unapproved safes or vaults should be strategically located regional distribution allowed to retain their storage privileges, centers have been provided by SED to and complete the determinations in time address such contingencies. to make any necessary alternative storage arrangements for the June 2007 One of the schools (Lockport High School) Regents examination period. was serving as a host school for another school in its district. Lockport High School 3. Remind school officials that sealed ordered examination materials for both itself packages of examination materials must and the other school. When the materials not be opened until the allowed time, were delivered, school officials opened all and sanction schools, as appropriate, for the materials, separated their materials from violations of this requirement. the other school’s materials, and sent the other school its materials. At Lockport High Shipments of Examination Materials School, the opened materials were stored inside locked Regents boxes in an approved To request examination materials from SED, vault. At the other school (Charlotte Cross the schools must complete a request form School), the opened materials were stored and submit the form to SED by a certain inside locked Regents boxes in a safe that date. SED then prints the materials that had not been approved by SED. have been requested, packs up each school’s order, and prepares the shipments for We immediately informed SED officials delivery. Each school’s shipment contains a about this unauthorized situation, and they packing slip of the materials sent. stated that it was unacceptable. SED immediately made arrangements for the According to the School Administrator’s examination materials to be removed from Manual, if a school wants to review an Charlotte Cross School and stored in an examination it is not administering, it should approved secure location at another nearby request the examination in a separate letter school. SED officials stated that Lockport to SED. It should not use the regular request High School has lost its storage privileges form for such examinations. However, four for at least one year, and Charlotte Cross of the schools in our sample did not comply School will be required to order its own with this requirement, as they used the examination materials in the future. regular request form to order examinations

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for review purposes only. The four non- be obtained from SED’s regional compliant schools are listed in the following distribution centers, it would be prudent for table. schools to avoid the need for such last- minute arrangements whenever possible. School Type County Academy of St. Also, if the packages are not inventoried Joseph High School Private Suffolk when they are delivered, excess packages Franklin High School Public Delaware are less likely to be identified in a timely Goshen High School Public Orange manner. If excess packages are not Sherburne-Earlville Public Chenango accounted for when the shipment is High School received, they could be stolen without detection and used to compromise the We note that SED routinely posts examination’s security. We note that 14 of unrestricted Regents examinations to its the schools in our sample received excess Internet website after the examinations are examination materials from SED. In most held. Accordingly, school officials who are cases, the excess consisted of one additional interested in reviewing the examinations can package of 25 exams. Schools are not print out the materials for themselves required to notify SED if they receive excess without having to worry about security materials. We recommend schools be precautions. We also note that, if schools do required to notify SED in such instances, send a separate letter requesting and be reminded that the excess materials examinations for review purposes only, the should be maintained as securely as the examination materials can be sent to the materials that are needed. schools after the examinations are held, when security either is no longer an issue We further note that at none of the 235 (for unrestricted examinations) or is less of schools we visited were shipments of an issue (for restricted examinations). We examination materials either incomplete or recommend SED remind school officials late. All the schools received what they that examinations wanted for review ordered, and the orders were delivered on purposes only should not be requested time. This performance by SED and its through the regular ordering process. delivery contractors is noteworthy.

The School Administrator’s Manual also Recommendations states that school officials should inventory the sealed packages of examination 4. Remind school officials that materials as soon after receipt as practical. examinations needed for review We found that 24 of the schools in our purposes only should not be requested sample did not comply with this through the regular ordering process. requirement, as they did not inventory the sealed packages of examination materials 5. Remind school officials of the inventory when the shipments were delivered. Instead, requirements for sealed packages of they waited as long as three days to perform examination materials. the inventory. As a result, the schools were increasing the risk they would not have all 6. Request that schools notify SED when the materials they needed on the day of the they receive unordered or excess examination. While additional materials can examination materials, and remind such

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Recommendations (cont’d) result of this incomplete and inaccurate storage information, SED is less able to schools that the excess materials should identify appropriate alternative storage be maintained as securely as the facilities for (1) schools that lack such materials that are needed. facilities (guest schools) and (2) schools whose storage privileges have been Monitoring by SED suspended because of security violations. During our visits, we noted that, in a number The School Administrator’s Manual states of instances, storage facilities that were last that SED “will make random unannounced inspected in the early 1980s are no longer visits to some schools after the examinations equipped to secure the volume of have been delivered to verify that the tests examinations currently administered. As a are being properly stored and that the result, the materials at those schools are not packages containing examination booklets, properly stored. In the absence of teacher dictation copies, and scoring keys inspections, SED must rely on school are not opened until the day that each officials to notify SED when their storage examination is to be administered.” We facilities no longer meet SED’s found that SED does make such visits, but requirements. However, school officials are the visits are not made regularly and not always doing this. We recommend SED relatively few schools are visited. For increase its inspection coverage and example, SED’s records indicated that, as of periodically survey schools that have not January 2007, only 57 of the schools in our recently been inspected to determine sample had been visited since 1992. SED whether their storage facilities still meet officials told us that, due to a lack of SED’s requirements. staffing, they did not visit any schools during the June 2006 Regents examination Recommendations period. As a result of this limited inspection coverage, SED has less assurance schools 7. Develop and implement a formal are, in fact, complying with the security program for conducting regular site requirements. visits to schools to verify their compliance with SED’s requirements for SED has a database of approved storage storing Regents examination materials. locations for examination materials. However, the database is incomplete, as it 8. Update the Regents examination storage contains information about safes or vaults at facility database to reflect the most only 574 locations (during the June current inspection information available. examination period, examination materials are typically sent to more than 2,000 9. Periodically survey schools that have not schools). We also found during our visits to recently been inspected to determine the schools that much of the information in whether their storage facilities still meet the database is out-of-date. In some SED’s requirements. instances, the information was out-of-date because an inspection had not been AUDIT SCOPE AND METHODOLOGY performed for several years; in other instances, the database was not updated We audited the actions taken by local when an inspection was performed. As a schools and SED in maintaining security

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over Regents examinations and records as participating in the January 2007 corresponding answer keys from the time Regents examinations. the material is received by the schools until the day the examinations are given. Our To make our sample representative, we audit covered the period April 1, 2006 selected schools from all regions in the through February 1, 2007. State; schools that were administering both a relatively large and a relatively small We interviewed SED officials and observed number of examinations; a number of host SED facilities to gain an understanding of and guest schools; a mixture of city, rural the procedures that are followed during and suburban schools; and a mixture of SED’s printing and storage of the public, private and charter schools. Our examination materials before their sample contained a total of 179 public distribution to the schools, and during the schools, 51 private schools, and 5 charter actual distribution process. However, we schools. The schools are listed in Exhibit A. did not audit SED’s compliance with these procedures or its controls over these During our visits to the schools, we processes. We also interviewed SED interviewed school officials responsible for officials and reviewed SED guidelines to the security of the examinations. At each identify (1) the procedures that should be school, we observed where and how the followed by the schools in securing the examinations were stored, and compared examination materials upon delivery and (2) this location to the location approved by the procedures that should be followed by SED. We also performed a physical SED in monitoring the school’s compliance inventory of the examinations on hand and with these security requirements. In compared our inventory to SED’s record of addition, we reviewed SED’s database of the number of items shipped to the school. approved storage locations for examination We conducted our performance audit in materials and its records documenting its accordance with generally accepted unannounced visits to schools during government auditing standards. Regents examinations periods. In addition to being the State Auditor, the We selected a judgmental sample of 235 Comptroller performs certain other schools and visited their Regents constitutionally and statutorily mandated examination storage location either during, duties as the chief fiscal officer of New or just prior to, the January 2007 Regents York State, several of which are performed examination period of January 23 through by the Office of Operations. These include January 26, 2007. The purpose of our visits operating the State’s accounting system; was to determine whether the schools had preparing the State’s financial statements; (1) stored the examination materials inside and approving State contracts, refunds, and locked Regents boxes in an appropriate safe other payments. In addition, the or vault, (2) not opened the sealed packages Comptroller appoints members to certain before the scheduled examination dates, (3) boards, commissions and public authorities, inventoried the sealed packages upon some of whom have minority voting rights. delivery, and (4) received only the numbers These duties may be considered and kinds of examinations needed. Our management functions for purposes of sample was selected from the 1,554 public, evaluating organizational independence private and charter schools listed in SED under generally accepted government

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auditing standards. In our opinion, these Within 90 days of the final release of this management functions do not affect our report, as required by Section 170 of the ability to conduct independent audits of Executive Law, the Commissioner of the program performance. State Education Department shall report to the Governor, the State Comptroller, and the AUTHORITY leaders of the Legislature and fiscal committees, advising what steps were taken The audit was performed pursuant to the to implement the recommendations contained State Comptroller’s authority as set forth in herein, and where recommendations were not Article V, Section 1 of the State Constitution implemented, the reasons therefor. and Article II, Section 8 of the State Finance Law. CONTRIBUTORS TO THE REPORT

REPORTING REQUIREMENTS Major contributors to this report include Brian Mason, Bill Clynes, Erika Akers, We provided draft copies of this report to Holly Thornton, Rebecca Tuczynski, SED and the 41 schools that had storage- Constance Walker and Dana Newhouse. related deficiencies for review and comment. (We directed school officials to provide their comments, if any, to SED for SED officials to consider in preparing their response to the draft report.) We considered SED’s comments in preparing this report. SED officials agreed with the nine recommendations made in the report and indicated specific actions they will take to implement them. A complete copy of SED’s response is included in this report as Appendix A.

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Exhibit A

Schools Tested by Auditors January 22, 2007 through January 26, 2007

Albany County (5) Clinton County (4) Bethlehem Central School Public Ausable Valley Central School Public Bishop Maginn High School Private Peru Central School Public Guilderland Central School Public Plattsburgh City School Public Ravena-Coeymans-Selkirk School Public Seton Catholic Central HS Private Shaker High School Public Columbia County (6) Allegany County (5) Acad-Christian Leadership Private Andover Central School Public Brookwood Center Private Genesee Valley School at Angelica Public Chatham Central School Public Scio Central School Public Hudson City School Public Wellsville Central School Public Ichabod Crane High School Public Whitesville Central School Public Taconic Hills Central School Public Broome County (6) Cortland County (1) Binghamton City School Public Cortland City School Public Johnson City Central School Public Delaware County (3) Maine-Endwell Central School Public Charles Loring Brace Residential Private Seton Catholic Central HS Private Franklin Central School Public Vestal Central School Public Sidney Central School Public Whitney Point High School Public Dutchess County (7) Cattaraugus County (5) Arlington Central School Public Allegany Limestone Central School Public Dover Union Free School Public Archbishop Walsh High School Private Pine Plains Central School Public Cattaraugus Residential Center Private Poughkeepsie City School Public Hinsdale Central School Public Red Hook Central School Public Olean City School Public Rhinebeck Central School Public Cayuga County (2) Roy C. Ketchum High School Public Auburn City School Public Erie County (12) Union Springs Central School Public Amherst Central School Public Chemung County (4) Bishop Timon High School Private Elmira Christian Academy Private Buffalo Acad-Sacred Heart Private Notre Dame High School Private Cheektowaga Central School Public Southside High School Public Cheektowaga-Sloan School Public Thomas A. Edison High School Public East Aurora Union Free School Public Chenango County (2) Hamburg Central School Public Norwich City School Public Kenmore-Tonawanda School Public Sherburne-Earlville H. S. Public Mount Mercy Academy Private

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St. Josephs Collegiate Institute Private Webster Christian School Private Western NY Maritime Charter Sch Charter Webster Schroeder High School Public Williamsville Central School Public Montgomery County (3) Essex County (3) Amsterdam City School Public Keene Central School Public Canajoharie Central School Public Lake Placid Central School Public Fonda-Fultonville School Public Schroon Lake Central School Public Nassau County (9) Franklin County (1) Bethpage Union Free School Public Saranac Lake Central School Public Farmingdale Union Free School Public Fulton County (4) Hempstead Union Free School Public Broadalbin-Perth Central School Public Holy Trinity Diocesan H. S. Private Johnstown City School Public Massapequa Union Free School Public Mayfield Central School Public Oyster Bay-East Norwich School Public Tryon Girls Center Private Roslyn Union Free School Public Greene County (3) Solomon Schechter School Private Cairo-Durham Central School Public West Hempstead School Public Catskill Central School Public Niagara County (3) Coxsackie-Athens Central School Public Lockport High School Public Hamilton County (1) Niagara Catholic Jr Sr HS Private Wells Central School Public Niagara Falls City School Public Herkimer County (3) New York City – Bronx (7) Dolgeville Central School Public Bronx Preparatory Charter School Charter Ilion Central School Public Herbert H Lehman High School Public Little Falls City School Public Hostos Lincoln Academy Public Jefferson County (4) J Levin HS Media & Communic Public Belleville Henderson School Public Mott Haven Village Prep H. S. Public Carthage Central School Public Preston High School Private Immaculate Heart Central HS Private South Bronx Preparatory H. S. Public Watertown City School Public New York City – Brooklyn (4) Lewis County (1) Brooklyn International HS Public Lowville Academy & Central Sch Public Brooklyn Technical HS Public Livingston County (2) The School for Legal Studies Public Geneseo Central School Public Urban Assembly Sch-Law & Justice Public Livonia Central School Public New York City – Manhattan (8) Madison County (3) John V. Lindsay Wildcat Academy CS Charter Brookfield Central School Public Lasalle Academy Private Holy Cross Academy Private Mesivta Tifereth Jerusalem Private Oneida City School Public Notre Dame School Private Monroe County (7) NYC Lab High School Public Bishop Kearney High School Private St. Michael Academy Private Industry School Private St. Vincent Ferrer High School Private Olympia High School Public Wadleigh Secondary School Public St. Josephs Villa of Rochester Private New York City – Queens (10) Thomas High School Public August Martin High School Public

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Bayside High School Public Oswego County (3) Benjamin Cardozo High School Public Gray Bodley High School Public Long Island City High School Public Oswego City School Public Queens HS Tching Lib Arts & Sci Public Paul V. Moore High School Public Renaissance Charter School Charter Otsego County (3) Stella Maris High School Private Cooperstown Central School Public St. Agnes Academic High School Private Laurens Central School Public The Summit School Private Oneonta City School Public William C. Bryant High School Public Putnam County (2) New York City – Staten Island (4) Carmel Central School Public Curtis High School Public Mahopac Central School Public Monsignor Farrell High School Private Rensselaer County (7) Port Richmond High School Public Averill Park Central School Public St. Joseph by the Sea High School Private Catholic Central High School Private New York City – Central (3) Columbia High School Public Bedford Stuyvesant Preparatory HS Public Hoosic Valley Central School Public Brownsville Diploma Plus H. S. Public Hoosick Falls Central School Public West Side High School Public Rensselaer City School Public Oneida County (7) Troy City School Public New York Mills School Public Rockland County (3) Notre Dame Jr Sr High School Private Albertus Magnus High School Private Rome Catholic Jr Sr High School Private Clarkstown North Sr H. S. Public Rome Free Academy Public Ramapo High School Public Sauquoit Valley School Public Saratoga County (5) Thomas R. Proctor High School Public Corinth Central School Public Westmoreland Central School Public Saratoga Central Catholic HS Private Onondaga County (7) Saratoga Springs High School Public Blessed Virgin Mary-Mother of God Acad Private Shenendehowa Central School Public Corcoran High School Public Waterford-Halfmoon School Public Fayetteville-Manlius Central School Public Schenectady County (4) George Fowler High School Public Niskayuna Central School Public Jamesville-Dewitt Central School Public Notre Dame-Bishop Gibbons HS Private Nottingham High School Public Schenectady High School Public Syracuse Acad of Science Charter Sch Charter Scotia-Glenville Central School Public Ontario County (2) Schoharie County (2) Canandaigua Academy Public Cobleskill-Richmondville School Public Honeoye Central School Public Middleburgh Central School Public Orange County (6) Seneca County (3) Goshen Central School Public Finger Lakes Christian School Private Heritage Jr High School Public Mynderse Academy Public John S. Burke Catholic H. S. Private Waterloo Central School Public Middletown City School Public St. Lawrence County (4) Monroe-Woodbury Central School Public HC Williams Sr High School Public Washingtonville Central School Public Norwood High School Public

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Potsdam Central School Public Warren County (3) St. Lawrence Central H. S. Public Glens Falls City School Public Suffolk County (7) Johnsburg Central School Public Academy of St. Joseph H. S. Private Queensbury Union Free School Public Brentwood High School Public Washington County (3) Central Islip Union Free School Public Cambridge Central School Public East Hampton School Public Granville Central School Public Patchogue-Medford School Public Hudson Falls Central School Public Port Jefferson School Public Wayne County (2) Southampton Union Free School Public Lyons Sr High School Public Sullivan County (3) Newark Senior High School Public Glory to God Christian H. S. Private Westchester County (10) Liberty High School Public Academy Our Lady Good Counsel HS Private Monticello Central School Public Archbishop Stepinac HS Private Tompkins County (1) Fox Lane High School Public Ithaca Sr High School Public John Jay Sr High School Public Ulster County (3) Mamaroneck High School Public Kingston Sr High School Public Maria Regina High School Public New Paltz Central School Public Roosevelt High School Public Saugerties Central School Public Sacred Heart High School Private Westchester Hebrew H. S. Private White Plains High School Public